- Key insight: Prosecutors say the teller used the drive-through window to issue dozens of cards for out-of-state accounts without customers present.
- What's at stake: The plea elucidates the granular compliance failures that contributed to TD Bank's historic $3 billion penalty and asset cap last year.
- Forward look: The former banker faces sentencing in June, while TD Bank continues a $1 billion remediation plan to fix its anti-money-laundering programs.
Overview bullets generated by AI with editorial review
A guilty plea this week by a former TD Bank employee elucidates some of the specific, granular mechanics of how he and others bypassed often nonexistent internal controls to facilitate a multimillion-dollar money laundering scheme in Colombia.
Leonardo Ayala, 25, admitted to conspiracy to launder monetary instruments and receipt of bribes by a bank employee, according to a press release from the U.S. Attorney's Office for the District of New Jersey.
The guilty plea is the latest connected to the bank's sprawling anti-money-laundering compliance saga, which resulted in a historic $3 billion penalty and an asset cap last year.
"AML remediation continues to be the bank's top priority, and we are actively cooperating with law enforcement to support their investigation," a TD spokesperson told American Banker last week regarding a guilty plea by one of Ayala's co-conspirators.
While previous disclosures in the TD matters focused on high-level program failures, court filings against Ayala and fellow tellers detail exactly how retail bankers earning modest bribes managed to launder $5.5 million through the U.S. financial system.
The case also provides a window into just how lax TD's monitoring was. In one instance, criminal accomplices emailed lists of names and dates of birth to Ayala's TD Bank address — which he used to order debit cards under those names.
The mechanics of the money laundering
In their case against Ayala, prosecutors described a scheme that heavily relied on abuse of remote servicing capabilities and other authorities granted to bank tellers.
The scheme started with a separate co-conspirator, identified in court documents as former employee
Nunez-Flores put these accounts under the names of people who had no actual control over the funds and seemingly no direct connection to the scheme — a way of shielding the actual beneficiaries of the money-laundering scheme from regulatory scrutiny.
In one instance, prosecutors said Nunez-Flores received from an accomplice an email containing the Colombian passport and U.S. visa of a 77-year-old female Colombian national, who would serve as the straw owner of the laundering account.
Prosecutors did not detail the source of the names used as faux owners. In similar cases, criminals have purchased stolen identities on illicit websites (sometimes called the dark web) to use for such purposes.
The account had only one straw owner, but the conspirators needed numerous cards to withdraw cash efficiently in Colombia. These multiple debit cards allowed them to circumvent daily withdrawal limits and rapidly liquidate funds.
So, the criminal organization bribed Ayala to order debit cards connected to the account, using identities of people who were not signers on the account. Prosecutors said in the Nunez-Flores case these were "fictitious employees" of the shell companies.
Accomplices sent names and dates of birth in emails to Ayala's work email while he was working as a retail banker at a TD branch in Doral, Florida. Ayala would then put in an order for debit cards linked to the shell company account.
In one instance prosecutors detailed, Ayala accessed a shell company account while manning the bank's drive-through window. Over the course of an hour, he issued 25 debit cards for the New Jersey-based account. He selected the "Mail to Customer" option to send the cards to an address in Plainfield, New Jersey, rather than handing them to a customer present at the branch.
"Ayala repeatedly and corruptly issued numerous debit cards for TD Bank accounts originally opened in New Jersey … despite knowing that he was being directed to do so by individuals that were not the identified account holder," prosecutors wrote in the criminal complaint.
Once activated, the debit cards ended up in Colombia, where the money laundering began.
Bribery fee schedules and evasion tactics
The court documents also reveal the specific price points for compromising a front-line employee. Ayala and his co-conspirators agreed to a "fee schedule" for his illicit services: $700 for opening a business account, $150 for a personal account, and $50 for each debit card order he placed.
To hide the bribe payments, Ayala used unwitting acquaintances as intermediaries, according to prosecutors.
In September 2023, he texted an acquaintance asking for a favor because "my boys telling me it wont let him send to me through zelle," according to the criminal complaint.
The acquaintance received a $900 peer-to-peer payment from the accomplice and forwarded the funds to Ayala.
Missing and weak internal controls
The details of the scheme highlight major shortcomings in TD's internal monitoring and guardrails against insider wrongdoing, for which the bank has since paid dearly.
First, the bank's systems allowed a Florida employee to issue dozens of debit cards for a New Jersey business account without the customer present and without flagging the unusual volume of card issuance for a single entity.
Second, the employee successfully overrode the bank's fraud defenses. When TD Bank restricted debit cards due to "questionable activity," Ayala unblocked them to allow the laundering to continue, according to prosecutors.
Third, the conspirators communicated openly on bank systems. Ayala used his corporate email address to coordinate with criminals who were not the account holders, creating a digital paper trail that compliance monitoring tools seemingly failed to flag.
The lack of oversight aligns with broader cultural failures at the bank, according to prosecutors. Internal communications revealed by the DOJ in previous filings showed
Ayala faces a maximum penalty of 20 years in prison for the money-laundering conspiracy charge and 30 years for the bank bribery charge. His sentencing is scheduled for June 11.
TD Bank has committed to a massive remediation plan, projecting it will spend $1 billion on anti-money-laundering fixes through 2026. The bank has also reduced its U.S. assets by $48 billion to comply with the asset cap imposed by the Office of the Comptroller of the Currency.
